Managed Care

Hotline Management

  • 1.  Hotline Management

    Posted 09-15-2017 11:07 AM
    ​Greetings all,

    I'm an ethics & compliance investigator for a managed care plan in Ohio. Recently, some discussion has taken place about how we should handle employee relations type (HR) type cases that come in through our employee ethics & compliance reporting hotline. Such types of cases are "on X/X/XX my supervisor spoke to me with an unprofessional tone during a meeting."

    What we have been doing historically is having the compliance officer evaluate the complaint for potential compliance issues. If none are identified, we document it in a report and close out the complaint with an action item to transfer the investigation to HR. I then am responsible for drafting a memo indicating the case is being sent to HR and sending it to our VP and Director of HR. Additionally, I inform the reporter that no compliance issues were identified and that the case is being transferred to HR for investigation. From that point on it becomes the responsibility of HR.

    So, with that said, the question that was posed was, what do other places to with their HR cases that come through their hotlines? I would love responses on how you guys manage these investigations and especially how you report back to the submitter.

    Thanks in advance,

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    Jim Snyder
    Corp Compliance & Ethics Investigative Specialist
    CareSource
    Dayton,OH
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    2019 HCCA Compliance Institute


  • 2.  RE: Hotline Management

    Posted 09-15-2017 11:49 AM
    Edited by Brenda Manning 09-15-2017 11:50 AM
    Hotline calls should all be handled the same way IMO: you simply triage them to the appropriate department. If it's something under HR's purview, which most typically are, you simply triage the complaint to HR. You should have a canned response that you put into your anonymous chat pod letting the submitter know the complaint was received and is under review and letting them know how they can communicate and what the conditions are for anonymity.

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    Brenda Manning, JD, CHC, CHPC

    The views expressed herein are my own and do not represent those of my employer. They are not meant to constitute legal advice or create an attorney-client relationship.
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    2019 HCCA Compliance Institute


  • 3.  RE: Hotline Management

    Posted 09-18-2017 06:26 AM

    Jim,

     

    Your description of the operational process for a compliance analysis and referral to HR is what I have found and experienced within the compliance industry.

     

    Shawn

     

    Shawn DeGroot, CHC-F, CCEP, CHRC, CHPC

    President

    Compliance Vitals

    Shawn@Compliancevitals.com

    #605-430-9291

     

     

     

    Sent from Mail for Windows 10

     




    2019 HCCA Compliance Institute


  • 4.  RE: Hotline Management

    Posted 09-18-2017 07:18 AM
    Briefly...understanding that folks will add their process specifics...here is the basic flow I've always followed.



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    Frank Ruelas
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    2019 HCCA Compliance Institute


  • 5.  RE: Hotline Management

    Posted 09-19-2017 08:00 AM
    ​Hi Jim,

    The process you are describing is very similar to the process at my workplace. Office of Compliance is responsible for the initial review to determine if there is a compliance issue. If it is determined a personnel issue we refer to HR and communicate back to the reporter that we did not identify a compliance issue and that the matter has been referred to HR. Although rare, Compliance will post questions for the anonymous reporter on behalf of HR and will forward to HR any answer that may come in. We mostly use standard/canned responses, except for follow-up questions and answers.

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    [Monica] [Portugal] [MA, CHC]
    [Chief Compliance Officer]
    [Alliance Behavioral Healthcare]
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    2019 HCCA Compliance Institute